Millions of employees may be exposed to blood and other potentially infectious material (OPIM) while at work and such exposure can present a serious health risk. In order to minimize the risk, the U.S. Department of Labor’s Occupational Safety and Health Administration (OSHA) has adopted the Occupational Exposure to Bloodborne Pathogens Standard, requiring employers to take affirmative steps to protect workers.
Included among the steps that employers must take to minimize exposure risk are: the establishment of an exposure control plan and the institution of effective housekeeping procedures; the use of engineering and work practice controls; the use of personal protective equipment; employee training; medical surveillance; making vaccinations available; the use of warning labels and signs; and other necessary actions.
What Standards Apply?
What Does the Standard Require?
The OSHA Exposure to Bloodborne Pathogens Standard requires that employers in industries where exposure to bloodborne pathogens is reasonably foreseeable (i.e., health care) take steps to minimize or eliminate the risk of exposure. For example, regulated employers must establish a written exposure control plan and are likely to be required to implement engineering and work practice controls; ensure that workers are provided (and use) appropriate personal protective equipment; and adopt certain housekeeping procedures that foster a clean and sanitary work environment.
What Are the Common Hazards and Solutions?
It is estimated that approximately 5.6 workers in the health care industry and other fields are exposed to bloodborne pathogens – pathogenic microorganisms that are present in human blood. Exposure to bloodborne pathogens can cause serious disease in humans. Among the most troublesome bloodborne pathogens are Hepatitis B Virus (HBV), which causes serious liver disease, and Human Immune Deficiency Virus (HIV), which causes AIDS.
Employers, therefore, need to be prepared to take proactive steps to minimize their workers’ foreseeable risk of exposure to blood and OPIM. Regulated employers are required to draft and adopt an exposure control plan. Such plan should include a summary of possible exposure scenarios, a listing of methods that should be used to minimize the risk of exposure (i.e.: the use of personal protective equipment; the adoption of specific housekeeping procedures), and a procedure for the evaluation of the circumstances surrounding an exposure that does occur.
Of course, it is not enough to simply list various methods designed to minimize the risk of exposure. Employers are also required to implement such methods–including the institution of work practice controls and the establishment of policies that mandate the use of personal protective equipment. Of particular note in the cleaning and maintenance industry, housekeeping procedures should be adopted that ensure that the workplace is maintained in a clean and sanitary condition. Specifically, housekeeping procedures should include a written cleaning and decontamination schedule, require that work surfaces that are contaminated be treated with an appropriate disinfectant, and provide for the effective handling and disposal of waste.
Employers should also establish a Hepatitis B vaccination program and make sure that all necessary hazard information is communicated to employees. Specifically, information concerning the hazards associated with bloodborne pathogens should be communicated through the use of warning labels, biohazard signs, and employee training.
OSHA generally does not consider maintenance personnel and janitorial staff employed in non-health care facilities to have a foreseeable exposure to bloodborne pathogens. Further, OSHA does NOT consider janitorial employees to be exposed to blood or OPIM when emptying waste containers that may contain discarded sanitary napkins or feminine hygiene products designed to absorb menstrual flow. The agency does, however, expect such products to be discarded in waste containers which are properly lined with plastic or wax paper bags in order to protect employees from physical contact with the contents.
In addition, OSHA does not consider exposure to feces, nasal secretions, sputum, sweat, tears, urine, vomit, or saliva to be regulated under the Occupational Exposure to Bloodborne Pathogens Standard.
Despite the general rule that such products and bodily fluids/secretions do not qualify as regulated waste under the Bloodborne Pathogens Standard, employers are reminded that, ultimately, it is the employer’s responsibility to determine which job classifications and specific tasks may involve potential exposure and take all necessary action to protect employees from such exposure.